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ATTACHMENT D

Record of Consultations for the Experimental Use Permits (EUPs) for Pesticides ICR

List of individuals/companies contacted1:

Dan Jenkins

U.S. Agency Regulatory Affairs Lead

Monsanto Company

Washington, DC 20005

Phone: (202) 383-2851

Email: daniel.j.jenkins@monsanto.com

Crystal Layton 

Regulatory Product Manager

Landis International, Inc. 

3185 Madison Highway

Valdosta, GA 31601 USA 

Phone: (229) 247-6472 

Email: clayton@landisintl.com

Jerry Wells

Syngenta Crop Protection, Inc.

410 Swing Road, P.O. Box 18300

Greensboro, NC 27419-8300

Phone: (336) 632-6324

Email: jerry.wells@syngenta.com

 

1 EPA did not receive any responses to the consultation questions
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EPA Consultation Questionnaire for the EUPs for Pesticides ICR

1) Publicly Available Data

i. Is the data that the Agency seeks available from any public source, or already collected 

by another office at EPA or by another agency?

ii. If yes, where can you find the data? (Does your answer indicate a true duplication, or 

does the input indicate that certain data elements are available, but that they don’t meet 

our data needs very well?)

2) Frequency of Collection

Can the Agency collect the information less frequently and still produce the same outcome?

3) Clarity of Instructions

i. The ICR is intended to require that respondents provide certain data so that the Agency

can utilize them. 

a) Based on the instructions (regulations, PR Notices, etc.), is it clear what you are 

required to do and how to submit such data?

b) If not, what suggestions do you have to clarify the instructions?

ii. Do you understand that you are required to maintain records? 

iii. Considering that there is no required submission format, is it difficult to submit 

information in ways that are clear, logical and easy to complete?

iv. Regarding the any [specific program] forms, do you use them? Are they clear, logical, 

and easy to complete?

4) Electronic Reporting and Record keeping 

The Government Paperwork Elimination Act requires agencies make available to the public 

electronic reporting alternatives to paper-based submissions by 2003, unless there is a strong 

reason for not doing so. One such reason is that, at the present time, the Agency is unable to 

ensure the security of CBI that might be transmitted over the Internet.

i. What do you think about electronic alternatives to paper-based records and data 

submissions? Current electronic reporting alternatives include the use of “web 

forms”/XML based submissions via the Agency’s Internet site and magnetic media-based 

submissions, e.g., diskette, CD-ROM, etc. Would you be interested in pursuing 

electronic reporting?
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Are you keeping your records electronically? If yes, in what format?

ii. Although the Agency does not offer an electronic reporting option because of CBI-related 

security concerns at this time

a) would you be more inclined to submit CBI on diskette than on paper?

 

b) what benefits would electronic submission bring you in terms of burden reduction 

or greater efficiency in compiling the information?

5) Burden and Costs

i. Are the labor rates accurate?

ii. The Agency assumes there is no capital cost associated with this activity. Is that correct? 

iii. Bearing in mind that the burden and cost estimates include only burden hours and costs 

associated with the paperwork involved with this ICR, e.g., the ICR does not include 

estimated burden hours and costs for conducting studies, are the estimated burden hours 

and labor rates accurate?

If you provide burden and cost estimates that are substantially different from EPA’s, 

please provide an explanation of how you arrived at your estimates.

iv. Are there other costs that should be accounted for that may have been missed?